September 28, 2020

To: Members of the South Lake Tahoe City Council
Mayor Jason Collin
Mayor Pro-Tem Tamara Wallace
Council Member Cody Bass
Council Member Brooke Laine
Council Member Devin Middlebrook

cc:      Joe Irvin, City Manager

Nick Exline, Chair, City of South Lake Tahoe 100% Renewal Committee
Meredith Anderson, Sum Ruderman, Jackson Realo, Jenny Hatch, Kai Lord-Farmer
Sierra Nevada Alliance

Dear Mayor Collin, Mayor Pro-Tem Wallace, and Council Members:

Due to the very technical content of this planning document, the limited time available for community education and outreach, and the fact that most businesses and residents continue to grapple with the impacts of the COVID-19 pandemic, it has been a challenge to properly engage our Tahoe Chamber members and solicit their input. We believe this is true for the broader community as well. That being said, as your staff and consultants have established a deadline for receiving comments, this letter has been prepared for your review and consideration.

Highlighting Our Concerns

• Understanding the City’s Original Intent in Adopting a 100% Renewable Energy Goal
• Proposed Strategy to “Electrify ”
• The Plan’s intent to embrace “Reach” code standards above California Title 24
• The Plan’s emphasis on regulations rather than incentives. Note: Chapter 6 reveals the scale and scope of what the City is proposing.
• The Plan’s stated intent for a “partnership with TRPA to support transportation”
• The Need for Greater Regional
• Additional Concerns, Comments, and Questions

This letter details each of these concerns on the following pages.

The Bottom Line – What We Are Requesting

Tahoe Chamber management respectfully requests that the City NOT adopt this Plan until such time as the City has engaged the business community, contractors, and the broader community to properly provide the context for this plan and solicit their input. The City should take at least two additional steps before any plan adoption: 1) Establish a technical advisory committee of professionals in the building industry to advise the development of this plan; and 2) Commission an independent economic impact analysis of the plan. The cost of what’s being proposed on businesses, homeowners, community organizations, and the general public is simply unknown at this time, although clearly it is significant, as revealed throughout the draft, particularly in Chapter 6.

Understanding the City’s Original Intent in Adopting a 100% Renewable Energy Goal We attended the 2017 meeting during which Council unanimously adopted a Resolution to support a goal of achieving 100% renewable energy by the year 2040. Perhaps erroneously, we believed the City was making this commitment to take on those opportunities directly under the City’s control. Examples: Solar panels at City facilities, shifting to electric vehicles in the City’s fleet to the extent practical, and taking additional steps to reduce the City’s carbon foot print, whenever and wherever possible. We were pleased the City felt strongly it should set an example for the rest of us in the community.

We are not clear on how or when the City Council’s commitment to a 100% Renewable Energy Goal evolved into the drafting of a broader Climate Action Plan. For the sake of public transparency and understanding, we believe the City should share information about how and when this transition occurred.

Proposed Strategy to “Electrify Buildings”

This is one of the most troubling aspects of the proposed plan. Outside of a few “stakeholders” (as identified on page 1-4 of Chapter 1 Introduction) there is either no one, or very few members the business or broader community who know that the Plan includes an Action Item to “Electrify Buildings.”* (Chapter 4, page 4-20 under Strategy 9: Existing Buildings).

*“This strategy focuses on reducing emissions from existing buildings by improving energy in existing buildings through energy efficient retrofits, replacing fossil fuel-powered appliances with electric appliances, and. Increasing on-site renewable energy sources.”

This strategy seems to assume that all electricity comes from renewable sources. That is certainly not the case with Liberty Utilities (nor most electric utilities) at least for the foreseeable future. It also assumes that Liberty can provide a sufficient supply of electricity to meet the requirements and increased demands of this strategy. This assumption is questionable, at best.

While the Plan references natural gas as an acceptable source of energy for some uses, overall, the Plan appears to downplay the use natural gas as an energy source of as inconsistent with the goals of the City’s draft Climate Action Plan. We are concerned and do not support the broad conclusion in your draft Plan that natural gas should be eliminated or considerably de-emphasized as an energy source within the City.

Here are just some of our concerns with this approach:

• There are many restaurant owners and chefs as well as people who cook at home who use and prefer natural gas-powered appliances. We anticipate they do not want to be forced to prepare food using electric appliances, such as stoves and
• In terms of health and safety for residents, visitors, and emergency service providers, a viable alternative for power outages (accidental or planned), other than natural gas, has not yet been identified. This is a particular concern during winter. While some see solar power as an alternative, there are drawbacks to its widespread use in the Tahoe Basin. We have many heavily shaded communities and snow covered roofs during winter. Solar panels also tend to collect pine needles creating the potential for a fire
• The TRPA has had a wood stove retrofit program for many years to address wood smoke in the air during the colder months. Property owners are provided with a list of compliant natural gas fireplaces and stoves and owners must certify at point-of-sale that their fireplace or stove is compliant. As drafted, your plan will create significant confusion and complications with this TRPA

In our discussions with your Climate Action Plan team, we appreciate that City officials appear open to giving Southwest Gas a year to develop and provide a suite of programs and measures, including a specific timeline for accomplishing greenhouse gas emissions reductions from the use of natural gas within the City. Note: We have reviewed the September 18, 2020 letter sent to the City by Southwest Gas Corporation in this regard.

The Plan’s Intent to embrace “Reach” Code standards about California Title 24 standards

This is not Tahoe Chamber’s area of expertise. However, we are sufficiently informed to agree with the concern expressed by the Contractors Association of Truckee Tahoe in their September 18, 2020 letter to the City which states: “Having a more restrictive building code than current strict requirements for green building practices in the State of California is burdensome and adds to the cost of development and redevelopment.”

The Plan’s Emphasis on Regulations Rather than Incentives

Our concern here is two-fold. 1) The direction laid out in this Plan is to impose another set of regulations and restrictions without first adequately engaging with businesses and the public to explain why this approach is necessary; and 2) No case studies are cited that document what California high Sierra resort communities like South Lake Tahoe have successfully accomplished to address GHG reduction, if any. If there are some examples, they should be included.

Perhaps existing Chapter 5, Adaptation and Resiliency, should be moved to the front of the Plan. It describes anticipated changes (increases) in average temperature, periods of extreme heat and extended drought, reduced snowpack, and the changes projected to affect our forests, meadows and the ecological functions of Lake Tahoe. These will combine to fundamentally change the recreational attractions and values the Lake Tahoe region has traditionally offered to locals and visitors alike. We believe this would be a more compelling way to engage the attention of those we need to educate as to why climate change planning and strategy implementation are so important and timely. We encourage you to add text that discusses the importance of acting now for the sake of our children, grandchildren, and future generations as a legacy contribution of our current generation.

The Plan should be crafted to appeal to people on a personal level. Otherwise, it remains nothing more than a set of recipes for making food no one will eat.

We recommend meaningful community outreach to help City officials understand what types of incentives will be needed to fund and stimulate Plan implementation, at both the individual and community level. The cost will be significant and businesses, property owners, and residents will need financial incentives and assistance to make the changes the Plan identifies. In some cases, the Plan may need to be adjusted to acknowledge realistic limitations.

Chapter 6 reveals the significant scope and scale of what’s being proposed in this draft Plan, including but not limited to new ordinances in the City’s municipal code and the following statements:

• “Consideration of staff time and capacity, as well as overall implementation effort, is needed to guide CAP ”
• “The implementing strategy matrix, outlined in Table 6-2, provides an example of the

initial prioritization and categorization of several of this CAP’s strategies and actions. The matrix will need to be fully developed after adoption of this CAP,* when City staff and stakeholder can contribute to and provide feedback on the prioritization process.”

* We believe this staff and stakeholder outreach should take place BEFORE Plan adoption.

• “While some measures will require funding only from public entities, others will result in increased costs for businesses, new construction, and ”
• “However, implementation of CAP strategies will result in substantial cost savings for the City and its residents over the long term.”
• There is no information in this Plan that supports this statement. If there are to be savings, how long will it be before those savings can be realized. Will there be incentives provided to support the level of business and resident investments required
• Will the City help businesses, property owners, and homeowners navigate through the list of “Funding Opportunities for Implementation” in Table 6-4? Or through the State of California’s “Climate Change Funding Wizard”?

Without any knowledgeable guidance, this seems a daunting task.

The Plan’s stated intent for a “partnership with TRPA to support Transportation Programs.”

In Section 4.2 (Chapter 4, page 4-6), the draft Plan states “Transportation represents the

City’s second largest emissions sector, accounting for approximately 32 percent of emissions in 2015.” Also, “The CAP’s transportation strategies focus on reducing emissions from on- road transportation sources, as well as reducing vehicle trip lengths and transitioning most trips to walking, biking, and public transit.”

In reviewing this section, it is important to understand the roles and responsibilities of each regional transportation agency and the City’s contributions to solutions. TRPA has a responsibility under the Tahoe Regional Planning Compact (and other federal and state requirements) to prepare and adopt a Regional Transportation Plan. In its role as the federally-designated Metropolitan Planning Organization for Tahoe (TMPO) and as the Regional Transportation Planning Agency (RTPA) in California, TRPA is principally responsible for planning as well as for the allocation of the limited federal and state funds it receives for transportation planning, project development, and project construction. The Tahoe Transportation District was established in Article IX of the Compact. (TTD) has the authority to plan, develop and engage in transportation and mobility project implementation as well as to operate public transit. TTD also has the authority to “Own and operate support facilities for public and private systems of transportation, including, but not limited to, parking lots, terminals, facilities for maintenance, devices for the collection of revenue, and other related equipment.”

The City is to be commended for, over recent years, taking a more active role in the planning, development, implementation, and in numerous cases, the maintenance of bicycle and multi- use paths within the City. As of this writing, other than passing through state dollars to the TTD for transit, the City does not allocate any of its own funds to support public transit.

We offer the following comments under Strategy 1: Collaboration-Transportation (COT) – Collaborate with Regional Transportation agencies to Reduce Transportation-Related GHG Emissions (in Chapter 4):

Action#        Action Items

COT-1

• Work with TRPA to help implement the projects in the Regional Transportation. Plan that are applicable to the City
  • TRPA is not a transportation implementation agency although they do allocate limited federal and state dollars for transportation projects.

•  Work with TRPA to implement Commute Tahoe program, which focuses on reducing vehicle miles traveled by
  • This program has yet to gain meaningful traction.

• Help promote the Linking Tahoe (Regional Transportation Plan) as a resource and/or support marketing efforts for alternative modes of transportation such as transit, biking, and walking.

• Ensure that proper marketing and information-sharing strategies are implemented to inform residents and visitors.
  • Funds available for marketing transit, biking and walking are extremely limited.

• Implement the program for City employees to be a model for the rest of the community
  • We are unfamiliar with this program.

COT-2

• Support TTD in its effort to explore implementing a “toll” or entry fee for vehicles entering into the Lake Tahoe Basin and the City similar to the fee used on Bay Area bridges or for national parks.
  • Yes, the City should support TTD’s efforts in this regard, but to date, the City Council has not positioned itself to do so. The lack of a regional revenue source of funding for transportation and mobility projects and transit services undermine the credibility of existing regional transportation plans, including the new Regional Transportation Plan just released by TRPA (Draft September 2020).

• Explore the potential for limiting the number of nonresident visitors and for providing residents with a locals’ pass or permit
  • We do not believe a legal mechanism exists to limit the number of nonresidents entering the Tahoe Basin.

• Use the revenues generated through the program to fund transportation projects that improve quality of life and reduce GHGs. If this proves not to be feasible, explore other options for securing a regional revenue source to support transportation projects and reduce the use of personal vehicle and thereby reduce GHG emissions.
  • First, please be specific about which “program” Plan authors are referring to in this section. Second, we strongly encourage Plan authors and all City elected officials and management to read the full One Tahoe study and recommendations.

In summary, to the extent the City’s Climate Action Plan relies on transportation, mobility, and transit solutions to support its goals of reducing GHG and VMT, one or more new sources of new revenue are essential. As indicated above, we respectfully urge Plan authors and City leaders to read the full One Tahoe study and recommendations.

The Need for Greater Regional Collaboration

We understand the City is working to address State of California requirements to reduce Greenhouse Gas Emissions (GHG), Vehicle Miles Traveled (VMT), and other human and infrastructure impacts contributing to climate change. However, for example, as the Plan recognizes (Chapter 3, page 3-2), “reducing GHG emissions consistent with the community’s goals will also require partnerships and individual efforts beyond the City’s control.”

The City can certainly demonstrate leadership, assuming the range of funding required is available, in acting to help address the impacts of climate change. However, a coordinated effort throughout the Tahoe region would seem to be a more effective approach. We are aware that TRPA has what the Agency calls the “Building Resiliency: Climate Change and Sustainability Initiative.”

This initiative is described in a staff report prepared for the September 30, 2020 TRPA Governing Board meeting as follows:

“Implementation of this strategic initiative will synthesize ongoing state and local climate actions into a coherent prioritized strategy for Tahoe. Much of the framework is in place already and align with the priorities adopted by this board. Collaborative governance will help identify what actions are being taken and where there is a need for TRPA to play a leading role. From these gaps an updated bi-state climate strategy that includes highest priority actions already underway and action strategies. This will be a comprehensive update to the existing Sustainability Action Plan. The strategy will support three approaches to climate action; development, infrastructure, and resource management.”

Is the City engaged with this TRPA initiative? If so, how do City officials see the relationship?

Additional Concerns, Comments and Questions

• In addition to ensuring an independent economic impact analysis is prepared, the Plan itself should include a funding strategy to show how Plan implementation can be judged as realistic.
• The draft CAP contains the following statement: “The City will conduct updated GHG emissions inventories at least every 3 years after the CAP is adopted (page 3-1 of Chapter 3). Does the City have an estimate of what this regular emissions inventory will cost?
• According to the draft Plan, the baseline City GHG Emissions Inventory was prepared in 2015. Based on the 3-year update commitment, is this inventory now out of date?
• The Tahoe Fire and Fuels Team (TFFT) should be added to the list of “Stakeholders Involved” in Action Item CS-1 in Chapter 4, page 4-28. TFFT is a multi-agency collaboration which maintains, annually updates, and coordinates implementation of the Multi Jurisdictional Fuels Reduction strategy for the Lake Tahoe region. Please refer to the team’s most recent Forest Action Plan, published by the California Tahoe Conservancy in August 2019.

Thank you again for the opportunity to review the draft City Climate Action and Plan and prepare and submit these concerns, comments, and questions. Again, we urge the City Council NOT to adopt this Plan until such time as the City has engaged the business community, contractors, and the broader community to provide the context for this plan and solicit their input. Businesses and residents are more likely to support and engage with a plan if they had a meaningful role in shaping it. As stated in Chapter 6 (page 6-3) “the success of the City’s CAP and GHG emissions reduction measures will depend on the participation of the City’s residents, businesses, and stakeholders.”

Respectfully submitted on behalf of the members and leadership of Tahoe Chamber,

Steve Teshara
Chief Executive Officer